Transfer Pricing

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Pricing methodology

Development of price setting methodology in controlled transactions between related parties within a group of companies.

Comprehensive Transaction Analysis

An integrated approach to structuring and pricing of the intra-group agreements, optimization of value-added chain (taking into account OECD recommendations as part of the control measures on base erosion and profit shifting - BEPS).

Diagnostics of business operations

Review of taxpayer’s operations aiming to establish, evaluate and develop measures to mitigate risks associated with the tax control of prices.

Documentation and Reporting

Preparation of transfer pricing documentation, including three-tiered documentation (country-by-country reporting, Master File, Local File) and notification of the participation in the MNE Group, as stipulated by the Kazakhstan legislation.

Tax inspections and appeals

Preparation for tax inspections, assistance with appealing of the tax inspection results, support with dispute resolution related to the tax control of prices in the transactions between the related parties.

Advanced Pricing Agreements

Evaluation of appropriateness, preparation of required documentation and information, support of the taxpayer with submission of application for conclusion of the advanced pricing agreements (including the agreement with the competent authorities of foreign states).

Transfer pricing ("TP") rules have existed in Kazakhstan for more than 20 years. During this period, Kazakhstan’s tax authorities have performed numerous TP audits many of which resulted in disputes ultimately resolved in court.

Recently, attention to TP has grown worldwide, both from authorities and businesses, including the framework for implementation of the initiatives developed by OECD for fighting base erosion and profit shifting (BEPS). Kazakhstan is no exception and implemented new types of TP reports. Nevertheless, revision of the Kazakhstan TP rules to bringing them in line with the best international practice is under consideration.

Along with the historic focus in Kazakhstan on export of resource commodities, increasing attention is paid to TP issues concerning financial transactions, purchase of services, import of consumer and industrial goods and licensing of intangibles.

We have assembled an extremely strong TP team consisting of  local and international experts covering Kazakhstan and Eurasian Region. We work with different clients across various industries, typically addressing questions such as:

  • Whether the Kazakhstan TP rules apply to transactions of the company concerned?
  • What are the TP requirements you need to comply with?
  • How to structure your international operations from a TP perspective?
  • How to identify TP risks and mitigate them; how to prepare TP documentation and a TP policy; how to design an internal function for dealing with TP?
  • How to prepare for a TP audit?
  • In case of an ongoing TP audit or TP dispute, what are the options to defend your position and to establish a dialogue with the tax authorities? Our long-term relationships with the tax authorities are extremely helpful in this context.

Contact us and we will provide you with comprehensive TP support. More information about the TP rules in Kazakhstan and assistance we offer is presented in our brochure.

Contact us

Michael Ahern

Michael Ahern

Partner, Tax, Legal and People, PwC Kazakhstan

Тел: +7 727 330 3200

Timur Zhursunov

Timur Zhursunov

Partner, Tax, Legal and People Services, PwC Kazakhstan

Тел: +7 727 330 3200

Nursultan Nurbayev

Nursultan Nurbayev

Director, Transfer Pricing, PwC Kazakhstan

Тел: +7 701 953 3535

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